cdn.ymaws.com€¦ · web viewpayroll technician cathleen bourquard accounts payable technician...

Berkshire Hills Regional School DistrictBusiness Office Procedure Manual

Superintendent Dr. Peter Dillon

Business Administrator Sharon Harrison

Heidi AlibozekPayroll Technician

Cathleen BourquardAccounts Payable Technician

Andrea WadsworthBusiness Office Accountant

Table of Contents

Part ISummary of Internal Control Polices and Law...............................................1

1. Compliance with Laws.......................................................................1

2. Security of Financial Records and Data..............................................5

3. Property Management Guidelines.......................................................7

4. Procurement Guidelines......................................................................8

5. Travel Guidelines................................................................................9

6. Consultants and Contractors...............................................................9

Part IIInternal Control Procedures..........................................................................11

1. General Accounting Procedures.......................................................11

2. Cash Management Procedures..........................................................12

3. Grant Receivable Procedures............................................................13

4. Payroll Procedures............................................................................15

5. Payroll Reporting…………………………………………………..22

6. Property and Equipment Procedures.................................................24

7. Accounts Payable Procedures...........................................................28

8. Accounts Payable Additional Procedures…………………………..30

9. District Accountant Procedures…………………………………….36

10. Management Reporting Procedures..................................................44

11. Anti-Fraud Response Procedures......................................................46

Appendix AGeneral Policy on Gifts

Procedures for Handling Gifts................................................................50

2

Part I SUMMARY OF INTERNAL CONTROL POLICIES AND LAWS

INTRODUCTION

Internal control policies provide the Berkshire Hills Regional School District with the foundation to safeguard its assets properly, implement the Berkshire Hills Regional School District School Committee’s policies, provide compliance with state and federal laws and regulations, and produce timely and accurate financial information.

1. COMPLIANCE WITH LAWS

The Berkshire Hills Regional School District will follow all of the relevant laws and regulations that govern the school districts within the Commonwealth of Massachusetts. Additionally, any Federal Government laws and regulations that relate to grant funding will be adopted as the grant funding is received. The following are specific policies and procedures of the Berkshire Hills Regional School District.

1.1. Record Keeping

1. To provide an accurate and auditable record of all financial transactions, the Berkshire Hills Regional School District’ records and accounts are maintained in conformity with generally accepted accounting principals as required by the Commonwealth’s statutes applicable to school districts.

2. Further, the Berkshire Hills Regional School District specifically requires that:

a. No funds or accounts may be established or maintained for purposes that are not fully and accurately described within the records of the Berkshire Hills Regional School District.

b. Receipts and disbursements must be fully and accurately described in the records.

c. No false entries may be made in the records.

d. No false or misleading reports shall be issued.

e. Payments may be made only to the contracting party and only for the actual services rendered or products delivered.

f. No false or fictitious invoices may be submitted or paid.

1.2. Organizational Conflict of Interest or Self-Dealing (Related Parties)

The Berkshire Hills Regional School District will follow MGL, Chapter 268A conflict of interest law and disclosure. Additionally, it may not be operated for the benefit of an affiliated or unaffiliated organization or an individual in his or her own private capacity or individuals related to the Berkshire Hills Regional School District or members of its management, unless the private benefit is considered merely incidental. This private benefit preclusion will extend to the following:

1. Sale or exchange, or leasing, of property between the district and an affiliated or unaffiliated organization or a private or related individual.

2. Lending of money or other extension of credit between an agency and an affiliated or unaffiliated organization or a private or related individual.

3. Furnishing of goods, services, or facilities between the district and an affiliated or unaffiliated organization or a private or related individual except for the rental of district facilities as specified in the Berkshire Hills Regional School District School Committee Policy Manual.

4. Payment of compensation, unless authorized by the Berkshire Hills Regional School District School Committee, by the district to an affiliated or unaffiliated organization or a private or related individual.

5. Transfer to, use by, or for the benefit of a private or related individual of the income or assets of the Berkshire Hills Regional School District unless specifically voted by the Berkshire Hills Regional School District School Committee.

Thus, the Berkshire Hills Regional School District will be guided by the principle of arms-length standards with all affiliated or unaffiliated organizations or with a private or related individual(s). Related party transactions shall include transactions between a school / district and members of the Berkshire Hills Regional School District School Committee, administration, employees, related individuals and affiliated companies. Related individuals within the scope of this definition include spouses, parents, children, spouses of children, grandchildren, siblings, father-in-law, mother-in-law, sister-in-law, and brother-in-law of a School Committee member or school district employee.

1.3. Political Contributions

No funds or assets of the Berkshire Hills Regional School District may be contributed to any political party or organization or to any individual who either holds public office or is a candidate for public office. The direct or indirect use of any funds or other assets of the Berkshire Hills Regional School District for political contributions in any form, whether in cash or other property, services, or the use of facilities, is strictly prohibited. The Berkshire Hills Regional School District cannot be involved with any committee or other organization that raises funds for political purposes.

1. The following are examples of prohibited activities include the following:

4

a. Contributions by an employee that are reimbursed through expense accounts or in other ways.

b. Purchase by the school district of tickets for political fundraising events.

c. Contributions in kind, such as lending employees to political parties or using the assets of the Berkshire Hills Regional School District in political campaigns.

2. SECURITY OF FINANCIAL RECORDS AND DATA

2.1. Security of Financial Data

1. The district’s accounting software (BUDGETSENSE) should be reviewed regularly by the Business Administrator and Director of Technology to ensure that only properly authorized individuals, utilizing a security password, can access or modify data.

2. The district’s financial data must be backed up by the Director of Technology daily to ensure the recoverability of financial information in case or hardware failure.

3. The Payroll Technician shall keep unclaimed paychecks and unclaimed pay statements in a secure location.

4. The Superintendent of Schools or the Superintendent’s designee shall secure all other financial data.

2.2. Security of School Documents

Originals of the following district documents are maintained and their presence is verified on a periodic basis.

1. Minutes of School Committee Meetings

2. Agreements

3. Leases

4. Insurance Policies

5. Vendor Invoices

6. Grant and Contract Agreements

7. Fixed Asset Inventory List

2.3. Record Retention and Disposal

5

1. Records are maintained for the following indicated minimum periods:

a. Records, documents, and other supporting evidence including paid, cancelled or voided checks, accounts payable records, vendors’ invoices, payroll sheets and registers of salaries and wages, employees’ time cards and other public documents are retained for seven years after the original entry date.

2. The following records supporting Federal contracts, as required by the U. S. Office of Management and Budget are retained for the indicated minimum periods:

a. For three years after submission of the final report of expenditures, all financial records including spreadsheets, salary information, invoices submitted and paid, and any other pertinent information, with the following exceptions:

i. If any litigation, claim, or audit is started before the expiration of the three year period, the records shall be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken.

ii. Records of equipment acquired with Federal funds shall be retained for three years after final disposition.

b. Permanently: Audit reports, annual district reports, School Committee minutes, tax and legal correspondence, labor contracts, insurance claims and policies, and retirement / pension records.

3. The disposal date determined under this procedure is the end of the fiscal year, or the date of final payment of government grants.

4. All records not supporting government grants or otherwise covered by rules of the Internal Revenue Service are retained for three years from the end of the fiscal year in which the records were originally prepared.

5. All financial records are maintained, by category, in chronological order and fiscal year.

6

3. PROPERTY MANAGEMENT GUIDELINES

3.1. Use of School Assets

No employee may use any of the School property, equipment, material or supplies for personal use without the prior approval of the Superintendent and/or Director of Facilities.

3.2. Use of School Credit Cards

District credit cards are permitted and overseen by Superintendent, Business Administrator, and Director of Facilities.

3.3. Property and Equipment

The Berkshire Hills Regional School District school department maintains detailed records and tags all government-furnished property and equipment.

3.4. Identification of Property

Lists of purchased materials shall be kept in databases kept by the technology department.

3.5. Record and Report of Property

1. The Berkshire Hills Regional School District maintains records for every item of property purchased for $5,000 or more as follows:

a. Name and description

b. Serial number, model number, or other identification

c. If title vests with any entity other than the school district, specific information relative to which specific entity

d. Location and condition of the equipment

e. Ultimate disposition data, including date of disposal, sales price, or method of disposal.

3.6. Physical Inventories

1. The Berkshire Hills Regional School District performs a physical inventory of all property valued in excess of $5,000 per unit on a periodic basis.

2. The physical inventory records include each such asset, its identification number, its location, and a brief description of its condition.

7

3. The physical inventory is reconciled to the detailed fixed asset list. Any differences are investigated and reconciled.

3.7. Disposal of Property and Equipment

1. No item of property or equipment shall be removed from the premises without the prior approval of the Superintendent or Director of Facilities.

2. As previously approved by the Berkshire Hills Regional School District School Committee, textbooks and materials, which are outdated or in poor condition may be discarded at the discretion of the building principal.

3. Any other items of value no longer needed by the school district shall be disposed of only after a vote by the Berkshire Hills Regional School District School Committee if the item is worth more than $500.

4. If items are not useful to other town departments, the Director of Facilities shall arrange for its disposal and shall ensure that any revenues obtained for the equipment shall be returned to the District’s general fund unless other arrangements have been previously made at School Committee Meeting.

5. If items are disposed of, appropriate adjustments shall be made of the physical inventory list.

4. PROCUREMENT GUIDELINES

4.1. The Berkshire Hills Regional School District procures only those items and services that are required to perform and mission and/or fill a bona fide need. Procurements are made using best value contracting, which includes assessing the best value considering quality, performance, and price.

4.2. MGL, Chapter 30B is required to be followed.

4.3. The district adheres to the following objectives:

1. Procurement will be completely impartial based strictly on the merits of the supplier and contractor proposals and applicable related considerations such as delivery, quantity, etc.

2. Make all purchases in the best interests of the district and its funding sources.

3. Obtain quality supplies / services needed for delivery at the time and place required.

4. Buy from responsible sources of supply.

8

5. Obtain maximum value for all expenditures.

6. Deal fairly and impartially with all vendors.

7. Maintain dependable sources of supply.

8. Be above suspicion of unethical behavior at all times; avoid any conflict of interest, related parties or even the appearance of a conflict of interest in the school district supplier relationships.

4.4. The district will execute a purchase order for all purchases.

The appropriate building principal and the Superintendent must approve such purchase order. Purchase orders greater than $500 must also be approved by the Superintendent. Final approval is done by Business Administrator for all Purchase orders.

4.5. All lease agreements will be evidenced by a signed agreement identifying all of the terms and conditions of the lease. All lease agreements must be approved by the Business Administrator and Director of Facilities of the Berkshire Hills Regional School District.

4.6 Any real estate agreement to rent or sell will require a beneficial interest disclosure as required in MGL Chapter 7, section 40J.

5. TRAVEL GUIDELINES

5.1 Employee Mileage Reimbursement

1. All employees are reimbursed at the standard mileage rate per mile as determined by the Internal Revenue Service for use of their own vehicle for business related travel. In addition, parking fees and tolls paid are reimbursable if supported by receipts.

2. All employees requesting such mileage reimbursement are required to furnish an expense reimbursement form containing the destination of each trip, its purpose, and the miles driven, approved by supervisor

3. Receipts for any parking fees or tolls paid must be attached to the travel report.

4. Reimbursement requests must be made within the fiscal year during which the expenses were incurred. Failure to submit reimbursement requests prior to the close of a given fiscal year will result in no reimbursement.

6. CONSULTANTS AND CONTRACTORS

9

6.1. Consultant Utilization

The utilization of all consultants and contract personnel are sufficiently evidenced by the following:

1. Details of all agreements (e.g., work requirements, rate of compensation, and nature and amount of other expenses, if any), with the individuals or organizations providing the services and details of actual services performed.

2. Consultants submit invoices including sufficient detail as to the time expended and the nature of the actual services performed.

3. The use of a management contract for educational and administrative services will clearly identify the contractor’s performance requirements, including student’s academic achievement, contractor’s compensation, and the district’s rights to educational curricula and intellectual property developed.

4. All consultants and contractors invoices are reviewed and approved by Business Administrator.

6.2 Independent Contractors

The use of consultants is closely monitored so as not to vary from the rules of the Internal Revenue Code. In particular, consultants will:

1. All consultants and contractors must submit a W9 for payment by Accounts Payable Technician. These services will be performed per details of agreement.

2. Adhere to a precise contract scope of services, recomputed or at least adjusted annually. This consultant agreement will specify the obligation of the consultant to pay his or her own self-employment taxes, if applicable.

3. Not receive any fringe benefits as such, although their fee may include provision for fringe benefits.

4. Not be assigned a permanent workstation.

5. Make their services available or work for a number of firms or persons at the same time.

6. Use their own stationery or time card in billing for services.

10

Part II INTERNAL CONTROL PROCEDURES

INTRODUCTION

The following section of the Guide will provide procedures, which will support the policies and laws referenced in Part I of the Guide.

1. GENERAL ACCOUNTING PROCEDURES

1.1. In this section, procedures are described for the overall accounting system design, accounting activity, and closeout of the accounts at year-end.

1.2. Overall Accounting System Design

1. Control Objective

To establish a coding structure that supports financial reporting and decision-making.

2. Major Controls

a. The Business Administrator for Berkshire Hills Regional School District is responsible for Designing the Chart of Accounts / Coding Structure.

b. To support the decision making, the Business Administrator for Berkshire Hills Regional School District shall be involved in ensuring that DOE guidelines, as updated July 1, 2001, are used for recording and reporting purposes using the district’s software.

1.3. General Accounting Activity


To ensure that all accounting entries are current, accurate, and complete.

2. Major Controls

a. Timeliness of Entries

All entries are made soon after the underlying accounting event to ensure the financial record and reporting are accurate.

b. Support Documentation

All entries are supported by adequate documentation that clearly shows the justification and authorization for the transaction.

11

c. Audit Trail

A complete paper trail should be kept so that the auditors will be able to reconstruct and / or justify all entries.

3. Procedures

a. Financial data on source documentation is verified against original documents (e.g., invoice, purchase order, etc.) by the Accounts Payable Technician before entering into the software system.

b. Each entry in the accounting software is reviewed and approved by the Superintendent and Business Administrator for Berkshire Hills Regional School District.

c. Non-recurring entries, such as for correcting entries, are prepared as circumstances warrant and submitted to District Accountant from District Treasurer with documentation attached.

1.4. Account Reconciliation and Close-out


To ensure the accuracy of financial records and reports.

2. Major Controls

Reconciliation of All Accounts and Sub-accounts

3. Procedures

a. Reconciliation of Berkshire Hills Regional School financial records are completed by the District Accountant.

b. The District Accountant for Berkshire Hills Regional School District shall reconcile all accounts and sub-accounts, or shall ensure that all such sub-accounts are reconciled, on a monthly basis.

c. At fiscal year end and after the annual audit, all accounts are closed out and the balances of revolving funds and grants are agreed to the audited financial statements.

2. CASH MANAGEMENT PROCEDURES

2.1. In this section, procedures are described for cash receipts.

12

2.2. Cash Receipts


To record receipts completely and accurately and to prevent the diversion of cash assets.

2. Major Controls

a. Cash Receipts Procedures

The Berkshire Hills Regional School District has internal control systems in place to monitor cash receipts and to ensure that deposits are made in a timely manner.

b. Internal Accounting Controls

i. Listed receipts and credits compared to accounts receivable and bank deposits.

ii. Accounts are reconciled with balances and reviewed by Treasurer.

2.3. Procedures

1. General

3. GRANT RECEIVABLE PROCEDURES

3.1. Grant Writing


To ensure that grant funding is pursued to the greatest extent possible.

2. Major Controls

a. The Director of Learning and Teaching has been assigned as the point person on all grants.

3. Procedures

a. All information relative to grant opportunities is funneled to the Director of Learning and Teaching.

b. Entitlement Grants

13

i. The Director of Learning and Teaching distributes the applications for entitlement grants to the appropriate administrator.

ii. The administrator will consult with the Superintendent to ensure that the proposed application is appropriate, given the requirements of the grant and the fiscal needs of the district.

iii. Care will be taken to ensure that any application prepared for submission will adhere to all laws and regulations, paying particular attention to the requirements relative to non-supplanting.

iv. The administrator will complete the grant application, ensuring that any positions within such grant application are specified at salary rates listed in collective bargaining agreements, if appropriate.

v. When the grant application has been completed, the administrator completing the application will meet with the Superintendent to review.

vi. The Superintendent will review the application and sign three copies in blue ink.

vii. The Director of Learning and Teaching will make the required copies of the grant and arrange to have the needed copies submitted via certified mail or its equivalent.

viii. The Director of Learning and Teaching will send a copy of the signed grant application to the grant author and the Business Administrator.

ix. The Business Administrator and/or District Accountant will file a copy of the grant in the grants area at the Central Office.

c. Grant Amendments

i. Any proposed amendments to grants, either entitlement or competitive, must be discussed with the Superintendent and Business Administrator prior to preparation.

ii. After consultation with the Business Administrator, the grant administrator may prepare a draft of the amendment.

iii. The administrator must then meet with The Business Administrator to ensure that the proposed amendment can be accomplished within the remaining fund balances.

iv. After the Business Administrator has cleared the amendment, the form shall be submitted to the Superintendent for signature.

v. The Superintendent shall sign three copies of the proposed amendment.

14

vi. The Business Administrator will make the required copies of the amendment and arrange to have the needed copies submitted via certified mail or its equivalent.

vii. The Business Administrator will send a copy of the signed amendment request form to the grant author / administrator.

viii. The Business Administrator and/or Accountant will file a copy of the amendment request in the original grant folder in the Central Office pending approval.

x. When approval of a grant amendment arrives, the Business Administrator shall make copies of it and distribute those copies to the grant author/administrator and the District Accountant.

d. Requesting Grant Payments

i. The Grant Administrator will work with the Business Administrator to monitor the expenditure of funds.

ii. The District Accountant shall be responsible for requesting additional funds from DOE at regular intervals throughout the year.

iii. The District Accountant shall ensure that the final grant payment is requested in a timely manner so that the District Treasurer prior to the close of the fiscal year will have received all funds.

iv. The Director of Learning and Teaching will work with the Business Administrator to ensure that the grant is reconciled to the balances carried by the District Accountant at the end of the grant.

V . The Business Administrator shall submit the final report on the grant within 60 days after the end of the project.

4. PAYROLL PROCEDURES

Payroll procedures are organized under six categories: personnel requirements, personnel data, timekeeping, and preparation of payroll, submission of payroll, distribution of checks or statements.

4.1. Personnel Requirements


To ensure that the School hires only those employees, full or part-time, it absolutely needs and exerts tight control over hiring new employees.

15

2. Major Controls

a. Payroll Procedures

The School has adopted payroll procedures for installing new employees on the payroll system and removing terminated employees from the system, as well as monitoring vacation and sick pay.

3. Procedures

a. New Employees

i. Request for new employees are initiated by the building principal or supervisor and submitted to the Superintendent.

ii. The Superintendent and/or Business Administrator shall review the request to ensure that it falls within the approved School Committee budget.

iii. The Business Administrator and/or District Accountant shall maintain a spreadsheet to ensure that the funding of the positions being vacated is greater than the cost of the new hires.

iv. A CORI is completed prior to the hiring of any new employee. CORI is derived and held in the Superintendent’s office.

v. Any individual being considered for a position shall ensure that there is a complete application packet on file. That packet shall include the following:

Letter of Application

Completed Application

Resume

Letters of Reference

Official Transcripts

Certification / License (when appropriate)

vi. References shall be checked prior to hiring.

vii. Any individual being hired shall receive a letter of hire, from the Superintendent’s office, detailing position, salary step, pertinent collective bargaining agreement or individual contract, actual salary, and date of hire.

16

viii. The individual being hired shall receive and sign a payroll contract and return the signed copy to the District Accountant.

ix. The individual being hired shall be given, and shall acknowledge receipt of (in writing), copies of the following:

Harassment Policies; (Sexual, Racial, Disability, Gender, Sexual Preference)

Internet Acceptable Use Policy;

Ethics Policy

E-mail Policy;

Restraint Policy.

b. Vacation and Sick Pay

i. Employees accrue vacation time based on either their collective bargaining agreement or his/her individual contract.

ii. Employees must secure the approval of their supervisors and superintendent in advance. The Payroll Technician reviews the request to ensure that the time is available and forwards it to the Superintendent for approval. Under usual circumstances, this approval for vacation and sick time should be secured two weeks in advance.

iii. Regular part-time employees will earn vacation time as detailed in the applicable collective bargaining agreement or in his/her individual employment contract. Vacation time is on a pro-rated basis for first year of employment.

iv. Employees’ vacation balances are adjusted as requested to reflect vacation time taken.

v. Sick leave taken is monitored against each employee’s available time and is recorded on a weekly basis.

vi. Unused vacation time is based on collective bargaining agreements, individual contracts, and state law. Per BHRSD up to 5 days of unused vacation can be rolled into the next fiscal year per approval of Superintendent.

c. Non-renewals

i. The appropriate Principal and the Superintendent will sign letters of non-renewal.

17

ii. Such letters will be given to the non-renewed individual by June 1 of any given year. The letter will be handed to the individual personally.

iii. The Principal shall require the individual to sign the bottom of the letter acknowledging receipt of the letter. If the individual refuses to sign the letter, the principal shall bring in a witness to document the fact that the individual has refused to sign the letter acknowledging receipt. The witness shall sign and date a statement verifying the fact that the Principal has delivered the non-renewal letter and that the recipient has refused to sign acknowledging its receipt.

iv. The Principal shall return the non-renewal letter (signed by the recipient or documented by a witness as having been given to the recipient) to the Administrative Assistant of the Superintendent immediately.

v. The Superintendent shall notify the Business Administrator that the individual has been non-renewed.

vi. The Payroll Technician shall remove the individual from the payroll effective June 30.

vii. The District Accountant handles all issues relative to insurance, COBRA, etc. for an individual who has not been renewed. The payroll technician shall cancel all other benefits to remove the individual from the Budgetsense payroll system. The District Accountant will cancel health and dental benefits from group billing invoices. The Payroll Technician handles all issues relating to pension for an individual who has not been renewed.

d. Terminations

i. Any time an administrator or supervisor is considering terminating an employee, the Superintendent shall be notified immediately.

ii. The administrator or supervisor and the Superintendent shall immediately consult with the School Committee attorney to ensure that all appropriate steps are taken relative to the termination.

iii. The Payroll Technician shall remove the individual from the payroll. The individual’s final pay is calculated and their withholdings are reconfigured to ensure the proper amounts have been collected.

iv. The District Accountant handles all issues relative to insurance, COBRA, etc. for an individual who has not been terminated. The Payroll Technician handles all issues relating to pension for an individual who have been terminated.

4.2. Personnel Data

18


To calculate and record payroll data accurately and completely for all employees.

2. Major Controls

a. Internal Accounting Controls

b. A precise paper trail covering all transactions is required.

c. The Superintendent approves changes in personnel data.

d. Separate payroll and personnel files periodically reviewed and reconciled.

3. Procedures

a. Changes to personnel data are initiated with a an Appointment Letter which is initiated by Principal/Administrator and approved by Superintendent.

b. The Payroll Technician processes the authorized changes to the payroll data.

c. District Accountant revises and reissues payroll contract.

d. A copy of appointment and revised contract are retained in the employee’s payroll file.

4.3. Timekeeping


To ensure that payment for salaries and wages is made in accordance with documented time records.

2. Major Controls

a. Timekeeping Procedures

b. Employees are instructed on the proper charging of time to assure the accuracy of recorded time to cost objectives.

c. Time Card

Labor hours are accurately recorded and any corrections to timekeeping records, including the appropriate authorizations and approvals, are documented.

d. Internal Reviews

19

The Business Administrator monitors the overall integrity of timekeeping.

e. Internal Accounting Controls

Reconciliations of hours charged on time sheets to attendance records are made on a bi-weekly basis.

4.4. Procedures

1. Time Card Preparation

2. Time sheets for hourly employees are prepared on a weekly basis.

3. In preparing time cards, clerical personnel will:

a. Enter hours in ink.

b. Make all corrections in ink by crossing out the error and initialing the change.

c. Submit the completed time card to the appropriate supervisor for approval.

4. In preparing attendance sheets for salaried personnel, the clerical personnel will:

a. Enter attendance in ink.

b. Make all corrections in ink by crossing out the error and initialing the change.

c. Submit the completed time sheet to the appropriate supervisor for approval.

5. Approval and Collection of Time Cards

a. Time cards for all hourly personnel are forwarded to the payroll specialist on a weekly basis. The time frame ensures that all time cards are submitted in a timely manner.

b. The authorized forms are submitted to the payroll specialist for processing.

c. All attendance sheets for salaried personnel are submitted to the payroll specialist on a bi-weekly basis.

d. Attendance is recorded in the individual record of each salaried employee after verification that personal days and sick days fall within the number available for each.

6. Reconciliation of Payroll to Time Cards

a. Hours shown on time cards are reconciled to the hours recorded on the payroll forms by the payroll specialist.

20

b. The payroll technician will reconcile time sheets submitted for substitutes to the attendance forms submitted for salaried employees. All professional development days are identified, recorded, and reconciled to the substitute attendance record.

4.5. Preparation of Payroll


To ensure that payment of salaries and wages is accurately calculated.

2. Major Controls


3. Procedures

a. The Payroll Technician will assign all employees to the appropriate salary schedules, work calendars and salary account code. The bi weekly calculations are verified for all employees at the start of each work year and compared the budget allocation bi weekly.

1. All calculations of total prepared by the individual school are checked and verified by the payroll specialist.

2. The total time is recorded on the time sheets and the payroll technician verifies the number of employees.

3. The school or department secretary or department supervisor forwards approved time cards to the payroll specialist.

4. All calculations of total prepared by the individual school or department are checked and verified by the payroll specialist.

4.6. Payroll Payment


To ensure payment for salaries and wages by check or direct deposit is made only to employees entitled to receive payment.

2. Major Controls


21

All payroll checks and direct deposits are handled by the Payroll Specialist.

3. Procedures

a. After the Payroll Technician has cut payroll checks or direct deposit statements, these are returned to the school main secretary in sealed envelopes for distribution.

b. The payroll specialist shall sort the sealed envelopes for distribution.

c. Each school administrator will monitor those checks or statements, which cannot be delivered to the individual employee and will mail the check or statement to those employees who cannot pick up the check or statement.

4.7. Payroll Withholdings


To ensure that payroll withholdings are correctly reflected; and paid to the appropriate third parties in a timely manner.

2. Major Controls

a. Reconciliation of Payment and Payroll Withholdings

3. Procedures

a. All payroll withholdings are handled through the Payroll Technician.

b. Copies of the original withholding and benefit election forms shall be maintained in the individual employee’s payroll file.

c. The Payroll Technician in the Finance Office shall provide employees seeking to change their withholding or benefit elections with the appropriate forms.

d. W2 are held and maintained by Payroll Technician.

4.8 Payroll Open Enrollment

a. 403B yearly noticeb. FSA Annualc. Insurance for fiscal employees

5.0 Additional payroll task

The payroll technician will complete the following task on a daily, bi weekly, monthly, quarterly and annual basis.

22

A. Daily

1. Workers’ Compensation Accident Reports are filed as soon as they are received. The payroll technician will notify the workers’ compensation carrier of any lost time by employee and an earnings statement if necessary.

2. Complete retirement forms for employees, retirement account terminations and substitute buy back forms as requested.

3. Employment and wage verifications.

B. Bi Weekly

1. Submit direct deposit file for upload to the bank once the payroll has been processed.

2. Submit federal and state tax payments online and authorize the withdrawal of funds on due date.

3. Maintain a spreadsheet for 403(b) payroll deductions to be uploaded bi weekly to the district’s third party administrator.

4. Submit payment for wage garnishments and FSA deductions.

C. Monthly

1. Process a monthly warrant for payment of retirement deductions, disability deductions and life insurance deductions.

2. Prepare a non-check warrant for health and dental allocations.

D. Quarterly

1. Quarterly tax reconciliation. Submit Form 941, Employer’s Quarterly Federal Tax Return to the IRS. Complete Massachusetts Tax

2. Return on the Department of Revenue website. Upload Massachusetts Wage Detail file to state website.

E. Annually

1. Reconcile year end totals to W2 totals. Prepare W2 statements and send to the schools for distribution. Mail all other.

23

6. PROPERTY AND EQUIPMENT PROCEDURES

This section is organized into six parts” P & E acquisitions, record keeping over P & E, depreciation, inventory of P & E, disposal of P & E, and Government-furnished and School-acquired P & E.

6.1. Property and Equipment (P & E) Acquisitions


To control the acquisition of P & E and completely and accurately record fixed asset acquisitions in order to safeguard fixed assets from loss.

2. Major Controls

a. P & E Acquisitions Tied to Budget

All acquisitions of property and capital equipment are either designated in the approved budget or subsequently approved by the School Committee.

b. P & E Acquisitions Based on Approved Requests

Official approval is obtained before a P & E purchase is made. This is performed by reviewing the purchase order prepared for the item.

c. Internal Accounting Controls

Reconcile fixed assets acquisitions with capital expenditure authorizations.

3. Procedures

a. The School Committee submits capital budget requests annually for review and approval.

b. Authorization requests for the acquisition of fixed assets are reviewed and approved by the Superintendent.

c. Each item of property and equipment received is identified and tagged in a visible area on the asset.

d. A copy of purchase orders for capital expenditures is entered into the record for proper identification of all fixed assets to be included in the accounting records.

e. Information on each tagged asset is entered in the fixed asset inventory by Town Finance staff.

24

6.2. Recordkeeping Over Property and Equipment


To record fixed asset acquisitions, transfers and dispositions completely and accurately on a current basis.

2. Major Controls

a. Capitalization Policies

The district follows the policy of capitalizing all fixed assets purchased greater than $5,000.

b. Fixed Asset Classification

Fixed assets are accounted for by the following classifications: land, building, betterments, furniture, and computer hardware/software.

c. Complete Record of P & E Acquisition Costs

The fixed asset inventory list contains the full history of each capital asset acquired, original acquisition cost, and any costs incurred to prepare the asset for use.

3. Procedures

a. Asset acquisitions, transfers, and dispositions are entered in the fixed asset inventory list on a periodic basis.

b. The fixed asset inventory list is reconciled with the financial accounts on a periodic basis.

6.3. Depreciation

1. Procedures

2. The district records assets when acquired and records the historical cost of these items.

3. The estimated useful life of district assets is as follows:

a. Computers 5 years

b. Office Equipment 10 years

c. Vehicles 10 years

25

d. Office Furniture 10 years

e. Leasehold Improvements Life of lease or 5 years, whichever is greater

f. Building Improvements 15 years

g. Building 40 years

4. When calculating the current value of an asset, straight-line depreciation over the above estimated useful life shall be utilized.

6.4. Inventory Of Property And Equipment


To ensure that all recorded assets exist and are in use.

2. Major Controls


i. All property and equipment is tagged when received.

ii. Physical inventories are performed annually.

iii. Differences between physical inventories and amounts recorded on the fixed asset inventory list are analyzed and reconciled monthly.

3. Procedures

a. The Director of Finance secures a printout of the fixed asset inventory list by asset classification.

b. An inventory of fixed assets is taken annually by the Berkshire Hills Regional School District.

c. The physical inventory of fixed assets is compared to the figures recorded on the fixed asset inventory list.

d. Differences are investigated and resolved by the Town Accountant.

5.5. Disposal Of Property And Equipment


To ensure that assets no longer in use are disposed of in accordance with existing policies.

26

2. Major Controls

a. Disposal Policies

The School Committee has adopted policies on the disposition of property and equipment.


i. Use of fixed asset disposal authorization forms.

ii. Disposal or transfer of fixed assets only with proper authorization.

iii. Periodic count of fixed assets that is reconciled with the fixed asset inventory list.

3. Procedures

a. A determination is made by school personnel as to the usefulness of a fixed asset.

b. An asset disposal form is prepared with proper written authorization by the appropriate administrator.

c. The asset disposal form is reviewed and signed by the Superintendent.

d. A copy of the asset disposal form is routed to the Town Accountant who enters the dollar amount of the disposed fixed asset as a reduction in the fixed asset inventory list. Any proceeds realized from the disposition of these assets are turned over to the Town unless otherwise specified by Town Meeting.

6.6. Government-Furnished And School-Acquired Property And Equipment


To ensure that Government-furnished and School-acquired property and equipment are properly obtained, used, and managed during the life of a federal or state grant.

2. Major Controls

a. Record Keeping

The Berkshire Hills Regional School District maintains detailed records on all property and equipment.

b. Custody

27

All Government-furnished and School-acquired property and equipment, when not in use, is stored in a secure area.

c. Inventory

All Government-furnished and School-acquired property and equipment is inventoried.

3. Procedures

a. All Government-furnished and School-acquired property and equipment on Government grants are assigned tag numbers and properly identified with this number in the fixed asset inventory list.

b. On an annual basis, administrators inventory all property and equipment and ensure that fixed assets are being used for the purpose intended.

c. The disposition of Government furnished and School-acquired property and equipment is authorized by the Superintendent and reported to the proper Government Agency as required by that agency.

7. ACCOUNTS PAYABLE PROCEDURES

This section is organized into three major parts: accounts payable, purchasing, and expense reimbursement.

7.1. Accounts Payable


To ensure that invoices are accurately recorded on a timely basis for authorized purchases. Process PO’s from authorized requisitions through to the payment of invoices and manage encumbrances ensuring invoices are paid in a timely manner.

2. Major Controls

a. Reconciliation of Accounts Payable Records

b. Reconciliation of source data is performed periodically to ascertain the accuracy of accounts payable entries.

c. Internal Reviews

Internal reviews are conducted to determine if duplicate payments or overpayments exist.

3. Procedures

28

a. School secretary creates requisition for purchase order in Budgetsense.

b. Requisition is forwarded to Building Principal, then Superintendent, then Business Administrator.

a. Accounts Payable Technician creates Purchase Order; Follow-up and resolve any discrepancies with the orders or invoices with these purchase orders, mails to vendor.

b. Accounts Payable Technician sends receiving copy of Purchase Order to school, recipient much sign upon receiving item.

c. Invoices are received by the Accounts Payable Technician.

f. Approved invoices are entered into the financial software (BUDGETSENSE)

g. The accounts payable specialist reviews the above and enters the amounts into the software program.

h. Invoices are compared to the Purchase Order and the packing list.

i. Invoices without Purchase Orders are researched by Accounts Payable Technician, and sent to appropriate administrator for approval.

a. Exceptions are gas, utilities, and insurance

j. The invoice is reviewed for the following:

1. The nature, quality, and quantity of goods ordered and the related price.

2. Accuracy of all arithmetic calculations and extensions.

3. Completed 30B form if applicable.

g. Completed warrants are reviewed and approved by the Treasurer.

a. Two (2) Account Payable Warrants are done per month

b. Issue Manual Checks as approved and make appropriate journal entries

c. Process all voided checks and/or re-issue if necessary

h. The warrants are prepared for the signatures of three the five school committee members.

29

4. Purchase Discounts

a. The accounts payable specialist establishes all vendors within the accounting system upon initial use of the vendor. All vendors should provide verified street address and valid federal tax ID or social security number.

b. The accounts payable specialist reviews the invoice for any purchase discount date and ensures that the vendor file is established and properly capturing the discount period.

5. Reconciliation of Accounts Payable Records

a. Debit balances are resolved appropriately (e.g., an offset against other amounts due the vendor, requesting payment from the vendor, etc.)

8.0 Additional Accounts Payable tasks

1. Process and manage paperwork for District stipends paid to private contractors.

a. Receive appointment from Superintendent

b. Enter Vendor

c. Process payment for warrant

2. Create and distribute 1099’s. Maintain tax file for reference and audit purposes.

a. Create file in January

b. Upload to State and Social Security Online Business Services

3. Prepare detailed accounting system reports as requested.

4. Process End of Year (EOY) Grant Payments to State.

5. Coordinate communication with transportation contractor (s) and monitor bus radio emergencies. Maintain records for all field trips, athletic trips or special transportation requirements.

6. Sort all inter-office mail and distribute to/from other building appropriately.

7. Maintain the main office copier machine and postage machine and order supplies and service as needed.

30

8. Provide assistance to the Director of Operations to include: the purchase and ordering of materials and supplies, entering and processing of requisitions and purchase orders; follow-up with vendors regarding orders placed or services needed, etc.

8.1. Purchasing


a. To ensure that goods and services are required at fair and reasonable prices and the highest personal standards of conduct are maintained in all relationships with vendors, suppliers, and subcontractors.

b. To ensure that transactions are accurately classified and recorded in the financial records.

2. Major Controls

a. Purchase Requirements

The Berkshire Hills Regional School District administration has developed cost-effective and efficient purchase requirements in order to achieve full and open competition, meeting delivery schedules, controlling inventory and material, and expediting and following up on purchases.

b. Required Competition

The Berkshire Hills Regional School District utilize the following procurement guidelines per MGL Ch 30B:

i. Contracts under $5,000 – The district uses sound business practices when procuring goods and services for amounts less than $5,000.

ii. Contracts from $5,000 to $25,000 – The district seeks price quotes from at least three vendors and awards the contract to the responsible vendor offering the supply or service needed for the lowest price.

iii. Contracts greater than $25,000 – With the assistance of the School’s attorney, the district conducts a formal advertised competition using sealed bids or proposals. An award is offered to the qualified bidder who meets the district’s specifications and offers the lowest price.

iv. Where possible, the district utilizes the Commonwealth of Massachusetts – state contract, or the cooperative bids solicited by area collaboratives.

v. Public construction laws per MGL Chapter 149 and Chapter 30, Section 39M are defined in the table on the following page.

31

c. Selecting the Vendor

The Berkshire Hills Regional School District select the most responsive and responsible vendor to provide required materials and services, and promotes competition in order to obtain fair and reasonable prices.

d. Internal Accounting Controls

i. Approval by the Superintendent of purchases for all purchases, then final approval by Business Administrator prior to purchase order finalization.

ii. Implementation of procedures that require the reporting of unethical conduct to the Superintendent and the subsequent restitution of any gain resulting from such conduct.

3. Procedures

a. Purchase Requirements

i. After approval of the annual budget, the Business Administrator reviews the district’s needs to uncover patterns of orders and opportunity for clustering orders to achieve volume discounts.

ii. In preparing a purchase requisition, the requestor identifies only minimum needs.

b. Processing Purchase Requisitions

i. Requisitions are approved by the appropriate principal or other supervisor and forwarded to the Superintendent’s Office using the BUDGETSENSE system.

ii. Requisitions must include the following:

A description of items ordered;

A cost estimate;

The required delivery information;

Quantity

The account to be charged; (DOE guidelines should be used to determine appropriate function and object codes.)

The requisition is approved electronically by the principal or administrator, Superintendent, then Business Administrator, the accounts payable specialist. Accounts Payable Technician creates Purchase Order from requisition.

32

c. Processing Purchase Orders

i. The Finance Office converts requisitions to purchase orders, sends a receiving copy to the building principal or administrator, and forwards the purchase order to the vendor.

ii. One copy of the purchase order is filed alphabetically by vendor by name, to track outstanding commitments.

d. Obtaining Bids and Quotations

i. The Director of Facilities ensures that the requesting administrator has obtained and documented the required quotations on transactions not expected to exceed $5,000, and has obtained these in writing for transactions between $5,000 and $25,000. All of these require the completion of the school’s “Compliance with 30B form” and the attachment of the required documentation. Items greater than $25,000 will require formal bid requests and evaluation before the purchase order is issued.

ii. In evaluating bids received, the recommending administrator performs and documents a cost or price analysis for submission to the Superintendent and the Director of Finance.

e. Negotiation and Award

Awards may be made to other than the low bidder in circumstances where the higher bid demonstrates best value contracting procedures to the district (can use MGL c30B as guide). In such situations, the administrator shall prepare a justification statement for such awards, furnishing a brief explanation of the factors leading to such a decision to the Superintendent and Finance Directors.

8.3. Expense Reimbursement


To ensure the district pays for only authorized business expenses.

2. Major Controls

a. Travel Policies

Collective bargaining agreements and individual contracts address the issue of travel reimbursement.

b. Employee Expense Reimbursement Documentation

Employees are required to obtain and furnish documentation for all individual expenses.

33

c. Internal Accounting Controls

i. Justification for travel approved by the Principal, Administrator, and the Superintendent.

ii. Documentation for incurred employee expenses.

d. Expense Reimbursement

i. An employee who seeks reimbursement for authorized travel expenses completes a travel report detailing the expenses incurred, attaching copies of supporting documentation.

ii. If payment was made by check, copies of both the front and back of the cancelled check must be provided.

iii. If payment by credit card, copy of statement with credit card number and name listed as verification of charge.

iv. The employee’s travel report reimbursement request is reviewed and approved by the Supervisor.

iv. All reimbursement requests must be submitted within the fiscal year in which the expenditure was made.

34

9. District Accountant Procedures:

9.1 Health and Dental Insurance

a. Active Employees1. Active employees working more than 19 hours are eligible for health and dental

insurance. 2. Active employees upon hire date have 30 days to decide if they will partake in

insurance.3. Open enrollment for insurance is Mid-May to Mid-June.4. Rates are determined by Berkshire Health Group.5. Insurance Maintenance feature in Payroll system is updated by Accountant yearly.6. New Hires insurance rate is calculated and entered into Payroll by Accountant.7. Insurance is paid 10 months for a 12 month period.8. Qualifying event is only reason for change outside of open enrollment.

a. Deathb. Loss of coveragec. Birthd. Marriage

9. Active employee over 65 does not have to sign up for Medicare Part B until retired.10. Make all changes to Deduction Master in Budgetsense.11. Make all changes necessary to employees in Budgetsense.12. Cancel insurance for terminated employees.13. Initiate COBRA paperwork for all terminated employees.

b. Retirees1. Upon retiring from District health insurance is continued for retiree.2. Upon retiring from District dental insurance is canceled.3. If Retiree is under 65, Active plan will stay in place.4. If Retire is over 65, Medicare becomes primary with Medex as supplemental.5. Spouse of Retiree follows same age guideline.

c. Reconciliation of Invoice

1. Health insurance and Dental insurance are billed monthly by Group Benefits Strategies

2. Invoice is reconciled to Excel spreadsheet listing all:a. Plansb. Active Employeesc. Retiree Employeesd. Retired Employees eligible spouses

3. Any discrepancy is reported to Group Benefit Strategies

36

4. Bill is coded and prepared by Accountant for Payroll Technician to enter in Budgetsense.

5. A bank transfer is made from Money Market to Accounts Payable for invoice6. Transfer is recorded in Budgetsense by Accountant.7. Wire transfer is initiated by Accountant and approved by District Treasurer.8. All entries recorded in Cash Flow spreadsheet.

d. Mass Teachers Retirement System Reconciliation

1. New Retiree deductions reported to Mass Teachers Retirement System by District Accountant.

2. New Rates are reported to Mass Teachers Retirement System by District Accountant.3. All Changes to retiree status reported to Mass Teachers Retirement System by

District Accountant.4. Mass Teachers Retirement System check received monthly5. Payment reconciled to Excel spreadsheet in Health/Dental reconciliation.6. Payment coded and deposited by District Accountant, approved by District Treasurer.

e. Berkshire County Retirement Board Reconciliation

1. New Retiree deductions reported to Berkshire County Retirement Board by District Accountant.

2. New Rates are reported to Berkshire County Retirement Board by District Accountant.

3. All Changes to retiree status reported to Berkshire County Retirement Board by District Accountant.

4. Berkshire County Retirement Board check received monthly5. Payment reconciled to Excel spreadsheet in Health/Dental reconciliation.6. Payment coded and deposited by District Accountant, approved by District Treasurer.

f. Rates

1. Rates are set up Berkshire Health Group2. Accountant calculates Insurance Rate sheet for employee deductions.

g. Payroll Deduction

1. New Hires insurance rate is pro-rated by Accountant2. Insurance deduction is entered into the payroll system

h. Open Enrollment

1. Notice is sent to all employees and retirees stating dates of Open Enrollment

37

2. Open Enrollment allows employees an opportunity to add, change or cancel health and/or dental coverage.

3. Employee fills out Enrollment form and submits to District Accountant.4. District Accountant processes enrollment form through Group Benefit Strategies. 5. Each enrollment change is verified to Group Benefit Strategies invoice for accuracy.6. Once enrollment is confirmed, form is filed in the Business Office Payroll file.

9.2 Receivables

a. Cherry Sheet1. Cherry Sheet is available online on mass.gov2. Cherry Sheet Disbursements and Assessments are wired monthly to Accounts

Payable account3. Disbursement is confirmed via VendorWeb.4. Disbursement is coded and recorded by Accountant per Mass disbursement

guidelines.5. Internal Control: Treasurer reconciles general ledger accounts.

b. Assessments1. Assessments are billed quarterly according to approved School Committee Budget2. Assessments are due Oct 01, Jan 01, April 01, and June 30th. 3. Assessments are wired to the Accounts Payable account4. Assessments are coded to Operating and Capital accounts by the District Accountant5. Internal Control: Treasurer reconciles general ledger accounts.

c. Facilities1. Facility billing is generated via receipt of Facility use form from Director of Facilities2. An invoice is created based on Facility use form by District Accountant.3. Custodial overtime and Building usage fee are billed to vendor by Accountant.4. Accountant receives payment for invoice.5. Accountant records and codes payment, District Treasurer certifies deposit of funds.6. Internal Control: Treasurer reconciles general ledger accounts to billing.

d. Accounts Payable/Student Activity/Payroll billing

1. Accounts Payable/Student Activity billing is generated via receipt of Accounts Payable payment through warrant process.

2. An invoice is created based on Accounts Payable receipt of payment and supporting backup by District Accountant.

3. Coding is provided by Accounts Payable and billed to appropriate Student Activity or Group by Accountant.

4. Accountant receives payment for invoice.

38

5. Accountant records and codes payment, District Treasurer certifies deposit of funds.6. Internal Control: Treasurer reconciles general ledger accounts.

9.3 Contracts

1. Contracts are generated yearly based on negotiated, signed contracts with respective bargaining groups.

i. Unit Aii. Unit C

iii. Cooperativeiv. Administrative

2. Contracts include rate of pay, position, hours worked, days worked, credits, pdps, hourly rate.

3. Contract inserts are district calendar, ethics policy, sexual harassment policy, Exhibit E policy, signature page, and bargaining contract if applicable.

4. Individual contracts are kept in an excel file by District Accountant.5. Contracts are generated and distributed after negotiations are complete.6. Receipt of signed contract is recorded and tracked by District Accountant.7. Signed Contract is filed in the Payroll file of each employee.

9.4 My Learning Plan

Education tracking system that records and tracks Professional Developments Points and Credits.

a. Setup – New employees are setup by District Accountant

b. Maintenance – Periodically District Accountant reviews outstanding items and informs employee of its status.

c. Reporting – Credits and Professional Development Points are recorded in a manual excel file. These totals are reported on the employee’s yearly contract.

9.5 GrantsGrants are setup as revolving accounts in the General Ledger. They can be State or Federally

funded.a. Setup

1. Grant paperwork is received by Business Administrator.2. Once reviewed Grant is given to District Accountant to set up Chart of Accounts and

Fund numbers.3. A file is created by the District Accountant that holds original paperwork, entries for

Chart of Accounts, Grant reports, and any adjustments.

39

b. Budget1. According to the grant paperwork a Budget for the grant has been established2. Each line is coded and entered in the Budget Adjustment option through the Budget

portal.3. A Grants Management report is created to confirm Budget lines are properly

recorded.4. Grant Management report filed in folder in Business Office.

c. Request for Grant Funds1. Run a Fund Report2. Go to Mass DESE website3. Request funds based on Fund Report4. Print all requests for proof of Backup

d. Reconciliation1. Grant funds are received2. Compare previous payments to those received3. Post revenue to appropriate Grant Revenue account4. Make copy of deposit for each Grant folder and Accounts Payable book

9.6 State Reports

a. October 01 Report

1. Records all Students in District as of October 01

2. Files are downloaded from Rediker by Director of Technology

3. Information is sorted by:

a. Gradeb. Townc. Districtd. Choicee. Tuition

4. Report is tallied according to grade and town of residence.

5. Assessment report will create percentage of responsibility for each member town.

b. January 01 Census Report

40

1. Records all Students in District and in Other districts/schools as of January 01

2. Data for Student listing is requested by District Account via letters to area schools, private, public, parochial, and homeschooled.

3. Information is sorted by:

f. Gradeg. Townh. Districti. Choicej. Tuition

4. Report is tallied according to grade and town of residence.

5. Census report is entered into MA DESE Security Portal for data reporting. This is done by March 01.

9.7 Budgeta. Timeline – created by Business Administrator, Accountant to follow assigned tasks

b. Confirmation of Budget Pages1. District Accountant receives master budget from Business Administrator2. District Accountant receives all budget pages from other Administrators3. District Accountant compares budget pages to Master budget. 4. Discrepancies are investigated and/or corrected

c. Construction of Budget Book1. District Accountant receives budget book from Business Administrator2. District Accountant contacts district Town Clerks for count of how many books are

needed.3. Budget book had color and black and white pages.4. Color pages are printed on color machine5. Black and white pages are printed on regular copier6. Pages are interspersed, collated, and bond by District Accountant

9.8 Tuition – Tuition billing is based on Tuition segment of October 01 report

a. Town Billing1. Richmond2. Hancock3. Otis/Sandisfield

41

b. Parent Billing – any parent out of state or out district/choice option

c. Process:1. Listings of students are calculated based on grade. 2. SPED students will be costed at rate of service per Direct of Special Education3. District Accountant sends invoice monthly beginning with November.

9.9 Cash Flowa. Entries – District Accountant records all entries in Cash Flow to determine district’s

ability to borrow.

b. Reconciliation – District Accountant reconciles each month to the general ledger and each bank account statement.

9.10 Bankinga. Accounts Payableb. Payroll – sweeps to Payroll, always has zero balancec. Greylock Credit Union –print statement on lined. Scholarshipse. Student Activityf. District Money Marketg. Flexible Spending Accounth. Food Service

9.11 Monthly Financialsa. Summary Pageb. Balance Sheetc. Bank Account Sheetd. Revolving Account Sheet

9.12 General Ledger a. Journal Entriesb. Account Reconciliations

9.13 Scholarshipsa. Awardsb. Reconciliation

9.14 Big Spreadsheeta. Maintenanceb. Budgetc. Contract

9.15 Monthly Online Paymentsa. Meal Tax

42

b. CMS-Medicarec. Berkshire Health Group

9.16 Life Insurance

9.17 Revenue Anticipation Note

43

10. MANAGEMENT REPORTING PROCEDURES

In this section, procedures are covered for supporting the annual budget and financial reporting.

10.1. Annual Budget


To support effectively the preparation of the annual budget and its periodic review.

2. Major Controls

a. Budget Process

The building administrators develop budget requests utilizing input from their faculties and School Councils. These requests shall include requests for operating budgets and for warrant articles. The budgets are submitted to the Finance Director. After compilation of the requests, the Finance Director for shall forward them to the Superintendent for initial approval.


Accuracy and completeness of the budget and projections

3. Procedures

a. In preparation of the annual operating and capital budgets, the building administrators consult with faculty members and his/her School Council. Requests for additional resources and / or significant programmatic changes shall be submitted in priority order.

b. Building administrators shall meet with the Superintendent and Finance Director to discuss the initial requests.

c. The Finance Director shall prepare the initial budget request, compiling the requests from the district administrators.

d. The Finance Director shall submit this preliminary budget request to the Superintendent for consideration.

e. After consultation with the School Committee, the Superintendent will adopt a final budget request to be submitted to Town Meeting for approval.

f. The Comptroller will enter the budget approved by Town Meeting.

10.2. Financial Reporting

44


To ensure the accuracy, completeness, and timeliness of financial reporting to support decision-making.

2. Major Controls

a. Schedule

Monthly managerial reports are prepared.

b. Review and Approval

Financial reports are reviewed for accuracy and completeness.

3. Audit

A certified public accounting firm audits the annual financial reports of the Berkshire Hills Regional School District.

4. Procedures

a. The Director of Finance may prepare periodic financial reports for the building principals and other administrators. Administrators may also print financial reports for their location.

b. The administrators will review the reports for accuracy.

c. The Superintendent shall report any significant trends to the School Committee.

d. If necessary, the School Committee will approve transfers from one account to another.

e. The Berkshire Hills Regional School District submit to an audit of its financial statements by a qualified certified public accounting firm as required by law.

10.3. Payroll Tax Compliance


To prepare and file required tax documents accurately and on a timely basis.

2. Major Controls

On a quarterly basis, tax filings are prepared by the Payroll Technician.

45

11. ANTI FRAUD RESPONSE PROCEDURES 11.1. Summary

1. Introduction

Berkshire Hills Regional School District is committed to its duty to ensure effective stewardship of public money and other assets and resources for which we are responsible. It is the policy of the Berkshire Hills Regional School District to prevent and deter all forms of fraud that could threaten the security of our assets or our reputation. Berkshire Hills Regional School District is committed to the prevention, detection, investigation and corrective action relative to fraud.

2. Definition

Fraud is a violation of trust that is defined as a deception deliberately practiced to secure unfair or unlawful gain. The term includes but is not limited to such acts as deception, bribery, forgery, extortion, theft, embezzlement, misappropriation of money or assets, false representation, the concealment of material facts relating to any of the above and collusion or conspiracy to commit any or all of the above.

3. What to do if you suspect fraudulent activity.

Berkshire Hills Regional School District recognizes there may only be a suspicion of fraud - thus any concerns should be reported to the Business Administrator. If the concern involves the Business Administrator, any concerns should be reported to the Superintendent. The Business Administrator has the primary responsibility for the investigation of all suspected fraudulent acts as defined in these procedures.

4. Actions

All cases of suspected fraud will be investigated and appropriate action will be taken.

11.2. Applicability

These procedures apply to all employees of the Berkshire Hills Regional School District.

11.3. Fraud

Fraud can cover many activities, however these procedures are directed primarily at financial matters. It may include, but is not limited to:

1. Misappropriation of Assets

a. Forgery, alteration or misappropriation of checks, drafts, promissory notes or securities

46

b. Unauthorized use, or disposition of funds or property (for example, misuse of Berkshire Hills Regional School District owned computer hardware, software, data and other records; use of Berkshire Hills Regional School District owned equipment, vehicles or work time for non Berkshire Hills Regional School District purposes)

c. Embezzlement

d. Theft

e. Falsifying time sheets or payroll records

f. Falsifying travel or entertainment expenses and/or utilizing Berkshire Hills Regional School District funds to pay for personal expenses or for personal benefit

g. Fictitious reporting of receipt of funds

2. Fraudulent Financial Reporting

a. Improper revenue recognition

b. Improper expense/expenditure recognition

c. Overstatement of assets

d. Understatement of liabilities

3. Expenditures and Liabilities for Improper Purposes

Payments in money or other property, including but not limited to such things as jobs for families and friends, use of vacation properties, discounted or free services in exchange for benefits and other things of value, bribes and kickbacks.

11.4. General Procedures and Responsibilities

1. Berkshire Hills Regional School District will investigate any suspected acts of fraud, or misappropriation of property. An objective and impartial investigation will be conducted regardless of the position, title, length of service or relationship with Berkshire Hills Regional School District of any person, group or organization reasonably believed to have committed fraud. Each Administrator is responsible for instituting and maintaining a system of internal control to provide reasonable assurance for the prevention and detection of fraud, misappropriations and other irregularities. Management should be familiar with the types of improprieties that might occur within their area of responsibility and be alert for any indications of such conduct.

2. The Business Administrator has the primary responsibility for overseeing the investigation of all suspected fraudulent acts as defined in these procedures. The Business Administrator will

47

immediately notify the Superintendent of any fraud investigation. The Business Administrator will involve the Coordinator of Business, School Committee Chair, and others within Personnel, Legal, or management as deemed appropriate.

3. All department heads or individuals, upon discovery of any violation of these procedures, must notify the Business Administrator of the violation. If it is determined by the Business Administrator that corrective action may be provided for internally within the department, the Administrator or individual will notify the Director of Finance as to the steps taken to correct the violation.

4. Upon conclusion of the investigation, the results will be reported to the Superintendent. All significant findings will be reported to the School Committee Chair. Where there are reasonable grounds to believe that a fraud may have occurred, the Business Administrator may report the incident to the appropriate authorities, which shall include the Superintendent and School Committee Chair, in order to pursue appropriate legal remedies. The Business Administrator will pursue every reasonable effort to obtain recovery of the assets.

11.5. Procedures for Reporting

Any employee who has knowledge of an occurrence of fraudulent conduct, or has reason to suspect that a fraud has occurred, shall immediately notify The Business Administrator. In cases where the employee has reason to believe the Business Administrator may be involved, the employee shall immediately notify the Superintendent unless the Superintendent is also believed to be involved, in which case the School Committee Chair should be notified.

11.6. Investigation

1. Upon notification or discovery of a suspected fraud, the Business Administrator shall immediately investigate the fraud. The Business Administrator will make every reasonable effort to keep the investigation confidential.

2. When deemed necessary, the Business Administrator shall coordinate the investigation with the Superintendent and/or the appropriate law enforcement officials. Legal counsel will be involved in the process, as deemed appropriate.

3. It should be noted that there may be certain instances of fraud that will be handled in the normal course of operations that will not result in a separate “investigation” by the Business Administrator. For these cases, periodic communications will be made to the Business Administrator updating the Director of the cases noted and actions taken.

11.7. Security of Evidence

Once a suspected fraud is reported, immediate action to prevent the theft, alteration, or destruction of relevant records shall be initiated. Such actions may include, but are not limited to, removing the records and placing them in a secure location, limiting access to the location where the records

48

currently exist, and preventing the individual suspected of committing the fraud from having access to the records. The records shall be adequately secured until the investigation is complete.

11.8. Confidentiality

All participants and all persons questioned in a fraud investigation shall keep the details and results of the investigation confidential so as not to violate an individual’s expectation of privacy.

11.9. Personnel Actions

If a suspicion of fraud is substantiated by the investigation, disciplinary action, up to and including dismissal and appropriate legal action, shall be taken by the Business Administrator and the Superintendent.

11.10. Whistle-Blower Protection

No employee of Berkshire Hills Regional School District or person acting on behalf of Berkshire Hills Regional School District in attempting to comply with these procedures shall:

be dismissed or threatened with dismissal;

be disciplined, suspended, or threatened with discipline or suspension;

be penalized or any other retribution imposed; or

be intimidated or coerced.

Violation of this section of the procedures may result in disciplinary action, up to and including dismissal.

If an allegation is made in good faith, but it is not confirmed by the investigation no action will be taken against the originator. If, however, the allegations were made in bad faith or without a justifiable basis, appropriate disciplinary action may be taken against the individual making the erroneous allegation.

49

Appendix A

Gift Procedures

Massachusetts General Laws Chapter 71, Section 37A

School committees of cities and towns and regional district school committees may accept grants or gifts for educational purposes from federal, state, county and municipal governments or agencies thereof, charitable foundations and private corporations and disburse the same for such purposes. Any amounts so received by a school committee of a city or town shall be deposited with the treasurer of such city or town and held as a separate account, and expended by said school committee without further appropriation, notwithstanding the provisions of section fifty-three of chapter forty-four. Any amounts so received by a regional district school committee shall be deposited with the treasurer of such regional school district and held as a separate account and expended by said committee.

If you are contacted by an individual or organization who wants to provide a gift to your school, please do the following:

1. Obtain a letter describing the gift and the purpose for which it is intended.

2. Forward the letter to the Superintendent of Schools and the Director of Finance. The Superintendent will review and place the bequest on a subsequent school committee agenda for the committee’s approval if the gift exceeds $500. If the gift is less than $500, the Superintendent can approve.

3. Forward the funds received to the Director of Finance. If the gift funds are for the region, the District Treasurer will deposit in a separate account, and the Comptroller will establish revenue and expense accounts for the gift. If the gift is for the local schools, the Director of Finance will forward the gift funds to the Town Treasurer to deposit in a separate account. The Comptroller will establish revenue and expense accounts for the gift.

4. The Comptroller will notify all parties when gift accounts are established.

Note: If the gift involves an activity in a particular school, please contact the school principal for initial approval of the activity. The principal will also need to approve any invoices that are paid from the gift.

50